Surestream Digital Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all our customers and will only collect and use personal data in the ways described here and in a manner consistent with our obligations and your legal rights.

1. Information about us

Surestream Digital Ltd

Limited company registered in England under number 09325114

Registered office: St Stephens House, Arthur Road, Windsor, Berkshire, England, SL4 1RU

VAT number: 218463211

Email address: help@surestreamdigital.com

Telephone number: +44197 552 0947

Postal address: St Stephens House, Arthur Road, Windsor, Berkshire, England, SL4 1RU

Surestream Digital Ltd is the data controller responsible for your personal data.

2. What does this policy cover?

This Privacy Policy explains how we use your personal data: how it is collected, how it is stored, and how it is processed. It also explains your rights under the law regarding your personal data.

We use cookies and similar technologies to improve your experience. For more information, please see our Cookie Policy.

3. What is personal data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (“GDPR”) as ‘any information relating to an identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier’.

Personal data, in simple terms, is any information relating to an individual that allows them to be identified. Personal data includes obvious information like name and contact details, but also includes less obvious information like identification numbers, electronic location data, and other online identifiers.

The personal data we use is explained in Part 5 below.

4. What are your rights?

Under the GDPR, you have the following rights, which we will always strive to protect:

• The right to be informed about how we collect and use your personal data. This Privacy Policy should provide you with all the information you need to know, but you can always contact us for more information or to ask questions using the contact details in Section 11.
  
• The right to access the personal data we hold about you. Section 10 will tell you how to do this.
  
• The right to rectify your personal data if any of the personal data we hold about you is inaccurate or incomplete. You can contact us using the details in Section 11 to find out more.
  
• The right to be forgotten, meaning the right to ask us to delete or otherwise remove the personal data we hold about you. You can contact us using the details in Section 11 to find out more.
  
• The right to restrict (e.g. prevent) the processing of personal data.
  
• The right to object to the use of your personal data for a specific purpose or purposes
  
• The right to data portability. This means that, if you have provided us with personal data directly, we are using it with your consent or to perform a contract. Furthermore, since the data is processed automatically, in many cases you can request a copy of that personal data for reuse with another service or company.
  
• Rights related to automated decision-making and profiling. We do not use your personal data in this way.
  

For further information about our use of your personal data, or to exercise your rights as described above, you can contact us using the contact details provided in Part 11.

If you have any concerns about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) (www.ico.org.uk)). We would, however, appreciate the opportunity to address your concerns before you contact the ICO.

Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time.

5. What personal data is collected?

We may collect some or all of the following personal data (this may vary depending on the relationship between you and the product or service requested):

• name;
  
• address;
  
• e-mail address;
  
• telephone number;
  
• payment information;
  
• phone location.
  
• approximate location data (such as country or region based on your IP address or phone number).
  

6. How is your personal data used?

Under the GDPR, we must always have a legal basis for using personal data. This may be because the data is necessary for the performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interest to use it. Your personal data may be used for one of the following purposes:

• Provide and manage your user account
  
• Provide you with our products and services. Your personal data is necessary to enter into a contract with you.
  
• Personalising and tailoring our products and services for you.
  
• Communicate with you. This may include responding to your emails or calls.
  
• Provide information by email that you have agreed to receive (you may opt-out or unsubscribe at any time by emailing us at help@surestreamdigital.com ).
  
• Provide information via text message that you have agreed to receive (you can opt out or unsubscribe at any time by texting the word STOP to the five-digit short code from which you received a text message)
  

We rely on the following legal bases to process your personal data:

• Contract – to provide the Services to you and manage your account
  
• Legitimate interests – to improve our Services, prevent fraud, and ensure security
  
• Consent – where you have agreed to receive marketing communications
  
• Legal obligation – where we are required to comply with legal or regulatory requirements
  

With your consent and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you via email and SMS with information, news, and offers about our products and services. You will not receive unlawful marketing or spam messages. We will always strive to fully protect your rights and comply with our obligations under the GDPR, and you will always have the option to withdraw your consent. We may also process your personal data for the purposes of fraud prevention, security monitoring, and protecting our Services from misuse or abuse.

7. How long will your personal data be retained?

We will not retain your personal data for longer than is necessary for the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements.

In general:

• Account data is retained while your account is active and for a reasonable period thereafter
  
• Transaction data is retained for up to 6 years to comply with legal and tax obligations
  
• Marketing data is retained until you withdraw your consent
  

We may retain certain data for longer where required or permitted by law.

8. How and where will your personal data be stored or transferred?

We may store or transfer some or all of your personal data to countries outside the European Economic Area (the "EEA" consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as "third countries" and may not have data protection laws as stringent as those in the UK and/or the EEA. This means we will take additional steps to ensure that your personal data is treated securely and protected as it is in the UK and under the GDPR, as follows.

We share your data with third parties, as described below in Part 9, who are based outside the EEA. The following safeguards apply to such transfers:

Where personal data is transferred outside the UK or European Economic Area (EEA), we ensure that appropriate safeguards are in place to protect your personal data. These may include adequacy decisions issued by the European Commission or the use of Standard Contractual Clauses or other legally approved mechanisms.

For further information on the particular data protection mechanism we use when transferring personal data to a third country, you can contact us using the contact details provided below in Part 11.

The security of your personal data is important to us, and we take a number of important measures to protect it. Further information about these measures can be provided by contacting us at help@surestreamdigital.com.

9. Do you share your personal data?

We may share your personal data with other companies in our group for the provision of our products and services.

We may occasionally contract with third parties to provide products and services to you on our behalf. These third parties may include payment service providers, mobile network operators, and technology providers supporting our Services. In some cases, these third parties may require access to some or all of the personal data we hold about you.

If any of your personal data is requested by a third party, we will take steps to ensure that your personal data is protected, treated securely, and in accordance with your rights, our obligations, and the third party's obligations under the law, as described above in Part 8.

If personal data is transferred outside the EEA, we will take appropriate steps to ensure that the personal data is treated securely and is protected as it is in the UK and under the GDPR, as explained above in Part 8.

In some limited circumstances, we may be legally required to share certain personal data, including your personal data, if we are involved in legal proceedings or to comply with legal obligations, a court order, or instructions from a government authority. We do not sell your personal data to third parties.

10. How can you access your personal data?

If you wish to know what personal data we hold about you, you can request details of that personal data and a copy of it (where such personal data is held). This is known as a "subject access request."

You can make a request by contacting us using the details in Section 11.

All subject access requests must be made in writing and sent to the email or postal addresses listed in Part 11.

There is generally no fee for a subject access request. If your request is "manifestly unfounded or excessive" (e.g., repetitive requests), a fee may be charged to cover the administrative costs of responding.

We will respond to your subject access request within one month of receiving it. We typically aim to provide a complete response, including a copy of your personal data, within this timeframe. However, in some cases, particularly if the request is more complex, it may take longer, up to a maximum of three months from the date we receive your request. We will keep you updated on our progress.

11. How can you contact us?

To contact us regarding any aspect of your personal data and data protection, including submitting a subject access request, you may use the following details:

Email address: help@surestreamdigital.com

Telephone number: +44197 552 0947

Postal address: St Stephens House, Arthur Road, Windsor, Berkshire, England, SL4 1RU

12. Changes to this Privacy Policy

We may periodically update this Privacy Policy. This may be necessary, for example, if the law changes or if we modify our business in a way that may affect the protection of personal data.
Any changes will be made available on our website www.surestreamdigital.com.